Comptroller's Decisions and Orders

In most enforcement litigation, the Comptroller of the Currency does not issue an order until after the presiding administrative law judge has issued a recommended decision and certified the record and Enforcement Counsel and Respondent(s) have filed exceptions to the recommended decision. See 12 CFR 19.38-40.

Final Decisions

The Comptroller issues final decisions after the presiding administrative law judge issues a recommended decision and certifies the record and Enforcement Counsel and Respondent(s) have filed exceptions to the recommended decision. See 12 CFR 19.38-40.

Interlocutory or Non-Dispositive Orders

OCC rules allow for Enforcement Counsel or Respondent(s) to move for an interlocutory review of an administrative law judge ruling by the Comptroller prior to the certification of the record. See 12 CFR 19.28. The Comptroller may review the administrative law judge's ruling when certain criteria are met and issue an order.

The Comptroller may issue other orders in accordance with his or her authority over the proceeding. See 12 CFR 19.4. Interlocutory or Non-Dispositive Orders are not issued in all cases and not all cases in which Interlocutory or Non-Dispositive Orders are issued will be resolved through a Final Decision by the Comptroller.

Comptroller's Decisions and Orders

Comptroller's Decisions and Orders are accessible by clicking on the links in the table below.

Note: The litigation in which the orders below were issued may be ongoing.

Case Number	Case Name	Interlocutory or Non-Dispositive Orders	Final Decisions and Orders
AA-ENF-2021-23	In the Matter of Nyema’sha Taylor, Former Teller and Institution-Affiliated Party, Wells Fargo Bank, N.A., Sioux Falls South Dakota, Atlanta, Georgia Branch	Notice of Submission of Proceeding for Final Decision (PDF) (Date: October 26, 2023)	Decision on Entry of Default (PDF) (Date: January 9, 2024) Order of Prohibition (PDF) (Date: January 9, 2024)
AA-EC-2021-22	In the Matter of Addisha Jackson, Former Customer Service Representative, JPMorgan Chase Bank, National Association Columbus, Ohio		Decision on Entry of Default (PDF) (Date: September 14, 2021) Order of Prohibition (PDF) (Date: September 14, 2021)
AA-EC-2021-11	In the Matter of Derline Cunningham, Former Retail Branch Manager and Officer, Citizens Bank, N.A. Providence, Rhode Island		Decision on Entry of Default (PDF) (Date: September 21, 2021) Order of Prohibition (PDF) (Date: September 21, 2021) Assessment of Civil Money Penalty (PDF) (Date: September 21, 2021)
AA-EC-2021-04	In the Matter of Jacqueline Brown, Former Senior Loan Processor, GN Bank, Chicago, Illinois		Decision on Entry of Default (PDF) (Date: February 1, 2022) Order of Prohibition (PDF) (Date: February 1, 2022)
AA-EC-2020-39	In the Matter of Denton Douglas, Former Vice President of Business Banking, PNC Bank, N.A. Wilmington, Delaware		Decision on Entry of Default (PDF) (Date: January 8, 2021) Order of Prohibition (PDF) (Date: January 8, 2021) Assessment of a Civil Money Penalty (PDF) (Date: January 8, 2021)
AA-EC-2020-38	In the Matter of Biagio Maffettone, Former Vice President and Home Mortgage Area Manager, Citizens Bank, N.A., Providence, Rhode Island	Order Extending Time for Filing Exceptions (PDF) (Date: February 25, 2022)
AA-EC-2019-82; AA-EC-2019-81; AA-EC-2019-71; AA-EC-2019-72	In the Matter of Carrie Tolstedt, Former Head of the Community Bank In the Matter of Claudia Russ Anderson, Former Community Bank Group Risk Officer In the Matter of David Julian, Former Chief Auditor In the Matter of Paul McLinko, Former Executive Audit Director Wells Fargo Bank, N.A., Sioux Falls, South Dakota	Order Denying Respondents’ Motion to Stay Proceeding (PDF) (Date: August 8, 2023) Order Regarding Enforcement Counsel’s Report and Request that Additional Documents be Added to the Certified Record and Notice of Submission (PDF) (Date: July 5, 2023) Order Granting Enforcement Counsel’s Motion to Seal (PDF) (Date: July 11, 2023) Order Regarding Respondents’ Motion for an Order Directing the Office of Financial Institution Adjudication to File a Corrected Certified Record and Index (PDF) (Date: May 12, 2023) Order Acknowledging Respondents’ Motion for an Order Directing the Office of Financial Institution Adjudication to File a Corrected Certified Record and Index (PDF) (Date: April 20, 2023) Order Granting Enforcement Counsel’s Motion to Unseal Certain Filings Related to the Stay of the Enforcement Proceedings Against Carrie Tolstedt (PDF) (Date: March 31, 2023) Order Granting the Parties’ Joint Supplemental Motion for Order Extending Time to File Exceptions (PDF) (Date: December 14, 2022 Order on Joint Motions (PDF) (Date: December 8, 2022)	Final Decision of the Comptroller of the Currency (AA-EC-2019-71; AA-EC-2019-72) (PDF) (Date: January 14, 2025) Final Decision of the Comptroller of the Currency (AA-EC-2019-81) (PDF) (Date: January 14, 2025) Order Granting Enforcement Counsel’s and Respondent Carrie Tolstedt’s Joint Request to Terminate the Enforcement Proceedings Against Respondent Carrie Tolstedt (AA-EC-2019-82) (PDF) (Date: March 20, 2023)
AA-EC-2019-58	In the Matter of Christopher Sangster, former Branch Manager, South Central Bank, N.A. Chicago, Illinois		Decision on Entry of Default (PDF) (Date: May 17, 2021) Order of Prohibition (PDF) (Date: May 17, 2021) Assessment of a Civil Money Penalty (PDF) (Date: May 17, 2021) Cease and Desist Order of Restitution (PDF) (Date: May 17, 2021)
AA-EC-2019-43	In the Matter of William Brian Mulder, Former Senior Vice President, Firstar Bank, N.A., Sallisaw, Oklahoma (Now Known as Firstar Bank)	Scheduling Order (PDF) (Date: February 21, 2020)	Decision on Entry of Default and Order of Prohibition, Cease-and-Desist Order Requiring Restitution, and Assessment of Civil Money Penalty (PDF) (Date: September 3, 2020)
AA-EC-2019-11	In the Matter of Walter F. Mills, former Personal Banking Representative, Santander Bank, N.A., Wilmington, Delaware		Decision on Entry of Default and Order of Prohibition (PDF) (Date: December 13, 2019)
AA-EC-2018-89	In the Matter of Hiren Patel, Former Chairman of the Board, Chief Executive Officer and Controlling Stockholder, The National Republic Bank of Chicago, Chicago, Illinois		Decision and Order (PDF) (Date: December 8, 2022)
AA-EC-2018-20	In the Matter of Laura Akahoshi, former Chief Compliance Officer, Rabobank, N.A., Roseville, California	Order Staying Equal Access to Justice Act Application During Ninth Circuit Appeal (PDF) (July 13, 2023) Order Granting the Parties’ Joint Motion for Clarification (PDF) (May 26, 2023) Notice of Submission of Proceeding for Final Decision (PDF) (Date: November 21, 2022) Order on Respondent’s Application to Rescind Notice of Submission of Proceeding for Final Decision and Accept Respondent’s Motion to Include Supplemental Facts (PDF) (Date: October 26, 2022) Notice of Submission of Proceeding for Final Decision (PDF) (Date: October 17, 2022) Order on Supplemental Briefing (PDF) (Date: July 1, 2022) Order Regarding Respondent's Motion for Enlargement of Time to File Briefing and Exceptions to Recommended Decision (PDF) (Date: March 3, 2022)	Final Decision Terminating the Enforcement Action (PDF) (Date: April 5, 2023)
AA-EC-2017-44; AA-EC-2017-45	In the Matter of Saul Ortega, Former Chief Financial Officer, Director, President, Chief Executive Officer, and Chairman of the Board In the Matter of David Rogers, Jr., Former Chairman of the Board, First National Bank, Edinburg, Texas	Order Staying December 1, 2023 Orders of Prohibition and Orders Assessing Civil Money Penalties Pending Judicial Review (PDF) (Date: December 7, 2023) Order Extending Time to Issue Final Decision (PDF) (Date: October 30, 2023) Order Extending Time to Issue Final Decision (PDF) (Date: June 29, 2023) Order Regarding Respondents’ Motion to Stay or Extend Exceptions Deadline (PDF) (Date: December 7, 2022) Order Setting Deadline for Enforcement Counsel to Respond to Respondents’ Motion to Stay or Extend Exceptions Deadline (PDF) (Date: November 21, 2022) Order Granting the Parties’ Joint Motion for Order Extending Time to File Exceptions (PDF) (Date: October 26, 2022) Order Granting the Parties’ Joint Motion for Leave to File Electronically and for an Order Permitting Electronic Service (PDF) (Date: October 26, 2022) Order Denying Respondents' Emergency Motion to Certify Issue for Appeal and Stay Proceedings Below (PDF) (Date: January 5, 2021) Order Granting Cross-Motions for Interlocutory Review and Vacating and Reversing in Part April 9 Order (PDF) (Date: December 18, 2020) Notice of Submission of Parties' Cross-Motions for Interlocutory Review for Final Disposition and Order Granting Respondents' Unopposed Request to Stay Proceedings (PDF) (Date: June 18, 2020) Order Denying Respondents' Motion for Interlocutory Review (PDF) (Date: June 16, 2020)	Final Decision of the Comptroller of the Currency; Order to Seal Certain Parts of Exceptions; Order of Prohibition of Respondent Saul Ortega; Order Assessing Civil Money Penalty Against Respondent Saul Ortega; Order of Prohibition of Respondent David Rogers, Jr.; Order Assessing Civil Money Penalty Against Respondent David Rogers, Jr. (PDF) (Date: December 1, 2023)
AA-EC-2017-03	In the Matter of Richard Usher, Former Head of EMEA FX Spot Trading, JP Morgan Chase Bank, N.A., Columbus, Ohio	Order Denying Enforcement Counsels' Motion for Interlocutory Review (PDF) (Date: April 22, 2021)
AA-EC-2015-24	In the Matter of William R. Blanton, Former Director and Interim Chief Executive Officer and Vice Chairman, individually and as an institution-affiliated party, United Americas Bank, N.A., Atlanta, Georgia	Order (PDF) (Date: March 9, 2017)	Order Assessing Civil Money Penalty (PDF) (Date: March 11, 2019)
AA-EC-2014-90	In the Matter of James E. Plack, individually and as a former institution-affiliated party of American Bank, Rockville, Maryland	Order Denying Respondent's Motion to Reopen Proceeding (PDF) (Date: February 1, 2021) Decision and Order Resolving Remaining Procedural Issues (PDF) (Date: April 25, 2016) Order Staying Consideration of Motions for Interlocutory Appeal (PDF) (Date: January 29, 2016)
AA-WE-2011-99	In the Matter of Borrego Springs Bank, N.A., Borrego Springs, California	Comptroller's Decision on Motion for Private Hearing and Treatment of Notice and Documents as Nonpublic (PDF) (Date: February 21, 2012)
AA-EC-2011-50	In the Matter of Patrick Adams, Former President and Chief Executive Officer T Bank, N.A., Dallas, Texas		Final Decision Terminating Enforcement Action (PDF) (Date: September 30, 2014)
OTS-AP-2010-03	In the Matter of Lawrence Dodge, Former Director, Co-Chief Executive Officer, and Institution Affiliated Party, American Sterling Bank, Sugar Creek, Missouri, OTS Docket 15909	Order Extending Date of Final Decision (PDF) (Date: July 25, 2012)
AA-EC-2009-98	In the Matter of Louis A. DeNaples, Chairman of the Board and Director, First National Community Bank, Dunmore, Pennsylvania	Order on Enforcement Counsel's Unopposed Motion for Stay of the Proceedings (PDF) (Date: September 5, 2013) Order on Enforcement Counsel's Unopposed Motion for Stay of the Proceedings (PDF) (Date: August 5, 2013) Order (PDF) (Date: July 9, 2013) Order on Enforcement Counsel's Unopposed Motion for Extension of Time (PDF) (Date: June 26, 2013) Order on Enforcement Counsel's Unopposed Motion for Extension of Time (PDF) (Date: June 21, 2013) Order on Enforcement Counsel's Motion for Extension of Time (PDF) (June 7, 2013) Order on Acting Comptroller's Decision (PDF) (Date: February 1, 2012)	Order (PDF) (Date: October 2, 2013)
AA-EC-2006-102	In the Matter of Carlos Loumiet, Esq., Equal Access to Justice Applicant		Initial Decision (PDF) (Date: July 20, 2010)
AA-EC-2006-53	In the Matter of Earl Ford McNaughton, Former President, Chief Executive Officer and Chairman of the Board, David Schimmele, Former Chief Financial Officer and Director, and Ted Walter, Former Loan Officer and Director, First National Bank of Fremont, Fremont, Indiana		Decision and Order (PDF) (Date: December 6, 2007)
AA-EC-2004-79	In the Matter of K. Patrick Kruchten, Chairman and CEO, Demian Kruchten, Director and Vice President, David Duhn, Director and President, Bruce Carr, Director and Vice President, First Integrity Bank, N.A., Staples, Minnesota	Decision and Order on Request for a Private Hearing (PDF) (Date: March 8, 2005)
AA-EC-2004-05	In the Matter of Gregory P. Healey, Former Chairman and Chief Executive Officer, Cashgate, Inc., Former Independent Contractor of National State Bank of Metropolis, Metropolis, Illinois		Decision and Order (PDF) (Date: November 22, 2004)
AA-EC-2003-21	In the Matter of Sharonda L. Herndon, Former Employee, Bank of America, National Association, Charlotte, North Carolina		Decision and Order (PDF) (Date: May 28, 2004)
AA-EC-2001-15	In the Matter of Dale E. Washburn, Equal Access to Justice Applicant		Decision and Order (PDF) (Date: May 2, 2002)
AA-EC-2001-02	In the Matter of Daniel C. Cadle, Change-in-Bank-Control Applicant, Malta National Bank, Malta, Ohio		Order (PDF) (Date: July 25, 2001)
AA-EC-2000-40	In the Matter of Gene Ulrich, Former Senior Vice President and Senior Loan Officer, Susan Diehl McCarthy, Former Vice President and Loan Officer, Six Rivers National Bank, Eureka, California	Order (PDF) (Date: February 27, 2003)
AA-EC-2000-18 AA-EC-2000-19	In the Matter of Michael R. Morgan, Former Vice President and Director, Robert S. Morgan, Former Chairman of the Board, and Todd W. Morgan, Former Director, The First National Bank & Trust of Pipestone, Pipestone, Minnesota, and The First National Bank in Garretson, Garretson, South Dakota	Decision and Order on Request for a Private Hearing (PDF) (Date: July 17, 2000)
AA-EC-2000-01	In the Matter of Fred A. Davis, Former President and Director, Malta National Bank, Malta, Ohio		Order (PDF) (Date: June 5, 2000)
AA-EC-1999-23	In the Matter of Carolyn D. Nelson, Former Assistant Vice President, Lone Star National Bank, Pharr, Texas	Order (PDF) (Date: June 21, 2000)	Decision and Order (PDF) (Date: August 8, 2000)
AA-EC-1999-01	In the Matter of Peter G. Weinstock, Esq., and Jeanne Breckinridge, Esq., Former Counsel to the Casey National Bank, Casey, Illinois	Decision and Order on Motion for Interlocutory Review (PDF) (Date: July 9, 1999) Decision and Order on Motion for Interlocutory Review of June 15, 1999 Order on Motion to Compel (PDF) (Date: August 16, 1999)
AA-EC-1997-07 AA-EC-1997-06 AA-EC-1997-05	In the Matter of Richard Salmon, Former Vice President, Bank of the Desert, N.A., Indio, California		Decision and Order (PDF) (Date: July 8, 1998)
AA-EC-1997-01	In the Matter of Massimilliano Locci, Former Employee, Instituto Bancario San Paolo Di Torino, New York, New York	Order (PDF) (Date: November 13, 1997)	Decision of the Comptroller of the Currency (PDF) (Date: January 26, 1998)
AA-EC-1996-06 AA-EC-1996-05	In the Matter of Charles R. Vickery, Jr., Former Senior Chairman of the Board, First National Bank of Bellaire, Bellaire, Texas		Decision and Order (PDF) (Date: March 31, 1997)
AA-EC-1994-27	In the Matter of William Vasa, Former Employee, First National Bank of Southeast Denver, Denver, Colorado		Decision and Order (PDF) (Date: September 7, 1995)
AA-EC-1994-21	In the Matter of Consolidated Bank, N.A., Hialeah, Florida		Decision and Order (PDF) (Date: June 8, 1995) Decision and Order (PDF) (Date: September 4, 1997)
AA-EC-1993-112	In the Matter of Janet F. Acker, Change in Bank Control Applicant, Interstate National Bank, Dallas, Texas	Order (PDF) (Date: July 27, 1995)	Order (PDF) (Date: October 18, 1995)
AA-EC-1993-91	In the Matter of John R. Givens, Equal Access to Justice Applicant, U.S. National Bank of Clayton, St. Louis, Missouri		Decision of the Comptroller (PDF) (Date: February 22, 1994)
AA-EC-1993-83	In the Matter of Notice of Change in Bank Control, Crown Charter National Bank, Dallas, Texas		Decision of the Comptroller of the Currency (PDF) (Date: December 9, 1993)
AA-EC-1993-74 AA-EC-1993-73	In the Matter of Paul Lowder, Former Director, Agent, and Institution-affiliated party, First National Bank in Kaufman, Kaufman, Texas	Decision of the Comptroller of the Currency (PDF) (Date: March 23, 1994)	Decision and Order (PDF) (Date: May 9, 1995)
AA-EC-1993-43 AA-EC-1993-42	In the Matter of Edward Towe, Former President and Director, and Thomas Towe, Former Director and Chairman of the Board of Directors, First National Bank & Trust, Wibaux, Montana	Decision and Order on Request for a Private Hearing (PDF) (Year: 1993) Decision and Order (PDF) (Date: February 23, 1994)
AA-EC-1992-147	In the Matter of Notice of Disapproval of Change in Bank Control, United Commerce Bank of Highland Village, N.A., Highland Village, Texas	Decision and Order on Motion for Private Hearing (PDF) (Date: December 2, 1992)
AA-EC-1992-115	In the Matter of Augustus I. Cavallari, Participating in the Affairs of Summit National Bank, Torrington, Connecticut (Insolvent)	Decision and Order (PDF) (Date: November 13, 1995) Order (PDF) (Date: June 8, 1995)	Decision and Orders (Date: May 28, 1994), Notice of Technical Corrections (Date: August 21, 1994) (PDF)
AA-EC-1992-107	In the Matter of E.B. Chester, Jr., Former Director, Paul W. Powers, Former Chairman, Jerome M. Hause, Former President, Branson Hobbs, Byron A. Rose, Donald P. Hettermann, R. Edgar Johnson, and Peyton F. Perry, Former Directors of Cherry Creek National Bank, Denver, Colorado (Failed)	Decision and Order (PDF) (Date: November 18, 1992)
AA-EC-1992-102	In the Matter of First National Bank of Chicago, Chicago, Illinois	Order (PDF) (October 14, 1994)
AA-EC-1992-21	In the Matter of Michael A. O'Connell, Former President and Director, Metropolitan National Bank, McAllen, Texas		Decision of the Comptroller of the Currency (Date: June 4, 1993), Order to Cease and Desist (Date: June 4, 1993), Administrative Law Judge's Recommended Decision (Date: February 2, 1993) (PDF)
AA-EC-1991-190	In the Matter of Wesley Godfrey, Jr., Former Officer and Director, Security National Bank, Shreveport, Louisiana		Decision of the Comptroller of the Currency (PDF) (December 14, 1992)
AA-EC-1991-175	In the Matter of Mark D. Dunlap, Chairman of the Board, President, and Chief Executive Officer, New Richmond National Bank, New Richmond, Ohio	Decision on Request for Private Hearing (PDF) (Date: November 13, 1991)
AA-EC-1991-153	In the Matter of Preston J. Brooks, Former President and Chairman of the Board, First National Bank of Deport, Deport, Texas		Decision of the Comptroller of the Currency (Date: June 17, 1993), Assessment of Civil Money Penalties (Date: June 17, 1993), Final Decision (Date: August 6, 1993) (PDF)
AA-MW-1991-136	In the Matter of John R. Givens, Former President and Director, U.S. National Bank of Clayton, St. Louis, Missouri		Decision of the Comptroller of the Currency (Date: June 9, 1993), Order (Date: June 9, 1993) (PDF)
AA-EC-1991-132 AA-EC-1991-131	In the Matter of John C. Riddle, Director, Texas National Bank, Houston, Texas	Decision on Request for Private Hearing (PDF) (Date: December 19, 1991)
AA-EC-1988-89 AA-EC-1990-91 AA-EC-1992-93	In the Matter of Texas National Bank, Baytown, Texas, Mayde Creek Bank, N.A., Katy, Texas, First National Bank of Bellaire, Bellaire, Texas	Decision and Order (PDF) (Date: February 26, 1993)
AA-EC-2006-102	In the Matter of Carlos Loumiet, Esq., Former Counsel to Hamilton Bank, N.A. (Closed), Miami, Florida		Final Decision and Order (PDF) (Date: July 27, 2009)